[Audit Report on Agricultural Leasing and Grazing Activities, Fort Peck Agency, Bureau of Indian Affairs]
[From the U.S. Government Printing Office, www.gpo.gov]
Report No. 98-I-703
Title: Audit Report on Agricultural Leasing and Grazing Activities,
Fort Peck Agency, Bureau of Indian Affairs
Date: September 30, 1998
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U.S. Department of the Interior
Office of Inspector General
AUDIT REPORT
AGRICULTURAL LEASING AND GRAZING ACTIVITIES,
FORT PECK AGENCY, BUREAU OF INDIAN AFFAIRS
REPORT NO. 98-I-703
SEPTEMBER 1998
AUDIT REPORT C-IN-BIA-002-97(D)
Memorandum
To: Assistant Secretary for Indian Affairs
Special Trustee for American Indians
From: Robert J. Williams
Assistant Inspector General for Audits
Subject: Audit Report on Agricultural Leasing and
Grazing Activities, Fort Peck Agency, Bureau
of Indian Affairs (No. 98-I-703)
INTRODUCTION
This report presents the results of our audit of
agricultural leasing and grazing activities by the Fort Peck
Agency. The objective of the audit was to determine whether
agricultural and pasture leases and grazing permits on the
Fort Peck Indian Reservation were managed by the Agency in
accordance with regulatory, lease, and permit requirements
and whether farming and grazing revenues in special deposit
(suspense) accounts had been distributed.
BACKGROUND
According to the Code of Federal Regulations (25 CFR 162 for
leasing and 25 CFR 166 for grazing), the Bureau of Indian
Affairs is responsible for approving leases and grazing
permits for individually owned land[1] or tribal land held
in trust that is negotiated by the landowners or their
representatives. The Bureau may also grant leases on
individually owned land on behalf of incompetent persons,
orphaned minors, undetermined heirs of estates, landowners
who have not been able to agree upon a lease or permit,
landowners who have given the Secretary of the Interior
written authority to execute leases or permits, and
landowners whose whereabouts are unknown. The Code of
Federal Regulations also states that leases and permits may
be executed either through negotiation or advertising and
that annual rents should provide for a fair annual return.
Specifically, the Code states that (1) agricultural leases
are not to exceed 5 years for dry-farming land and 10 years
for irrigable land but that, when lessees are required to
make substantial improvement to the land for the production
of specialized crops, leases can be made for 25 years and
(2) grazing leases and range permits are not to exceed
5 years except when substantial development or improvement
is required, in which case the maximum period is 10 years.
To improve the management, productivity, and use of Indian
agricultural lands and resources, the Congress enacted the
American Indian Agricultural Resource Management Act in
December 1993. The Act states that the Secretary is to
manage Indian agricultural lands to (1) protect and maintain
the highest productive potential on the lands, (2) increase
production and expand diversity on the lands, (3) manage
lands consistent with integrated resource management plans,
(4) enable Indians to maximize the potential benefits
available to them by providing technical assistance,
(5) develop Indian agricultural lands to promote self-
sustaining communities, and (6) assist trust and restricted
Indian landowners in leasing their land for a reasonable
annual return consistent with prudent management and
conservation practices. To meet these objectives, the Act
requires that 10-year Indian agricultural resource
management and monitoring plans be prepared and implemented
for Indian agricultural lands "within three years of the
initiation of activity to establish the plan."
The Act stipulates that the management and monitoring plans
be developed by tribes under self-determination contracts or
self-governance compacts or by the Bureau if tribes choose
not to contract or compact for the plans. The Act also
required that the Bureau, by June 1994, contract with a
non-Federal entity to conduct an independent assessment of
Indian agricultural land management and practices, which is
to include a comprehensive assessment of the improvement,
funding, and development needs for all Indian agricultural
lands. In addition, the Act required that the Bureau issue
final regulations to implement the Act by December 1995. In
June 1996, the Bureau issued proposed regulations; however,
the regulations had not been finalized as of August 1998.
Further, the Act changed many of the requirements specified
in the Code of Federal Regulations. For example, the Act
(1) authorizes the leasing of agricultural lands to the
highest bidder at rates below the appraisal amount after
"satisfactorily" advertising the leases when such action
would be in the best interest of the landowner, (2) provides
preference to Indian operators of agricultural leases when
authorized by tribal resolution and when the landowner
receives fair market value, (3) waives the requirement for
bonds when authorized by tribal resolution and when other
collateral is posted in lieu of bonds, and (4) extends the
maximum lease term for dry-farming land from 5 to 10 years.
The Fort Peck Agency of the Bureau's Billings Area Office in
Billings, Montana, is responsible for leasing and grazing
activities for the Assiniboine and Sioux Tribes on the Fort
Peck Indian Reservation. The Reservation encompasses almost
2.1 million surface acres in northeastern Montana, including
about 535,000 surface acres of allotted (individually owned)
lands and 381,000 surface acres of tribal lands. The
ownership interests in the allotted lands are severely
fractionated.[2] The remainder of the Reservation's lands
are in fee status (owned without restrictions) and are not
subject to the Bureau's trust responsibility. Through
September 30, 1996, the Fort Peck Agency performed all of
the program functions related to agricultural (farm and
pasture) leasing and grazing. However, effective October 1,
1996, the Assiniboine and Sioux Tribes assumed
responsibility for the grazing program under an Indian
self-determination contract except for fire protection
related to grazing lands.
As of December 31, 1996, the Fort Peck Agency had
administered 2,365 agricultural leases that consisted of
about 180,500 acres of allotted lands and 169,400 acres of
tribal lands. Annual rents for these leases totaled about
$3 million, of which $1.75 million was applicable to
allotted lands and $1.25 million was applicable to tribal
lands. The leases were all on a calendar year basis with 5-
year terms, but all of the leases did not expire in the same
year.
The Fort Peck Tribes administered 92 grazing range units[3]
under the self-determination contract as of December 31,
1996: 77 range units allocated by the Tribes to Tribal
members and 15 range units advertised and made available to
Indian and non-Indian ranchers. Grazing permits for these
range units were issued for the 5-year period of January 1,
1993, through December 31, 1997. The 92 range units had
annual grazing fees that totaled $504,200, which consisted
of $262,700 applicable to 176,493 acres of allotted land and
$241,500 applicable to 183,031 acres of tribal land. The
Billings Area Director established minimum grazing rates
for the range units that were allocated to Tribal members.
The Fort Peck Agency had 15 staff assigned to the real
estate services program, and 3 of the staff were responsible
for all aspects of agricultural leasing. The fiscal year
1997 budget for the Agency's real estate services program
was $437,709.
SCOPE OF AUDIT
The audit was performed at the Billings Area Office and the
Fort Peck Agency in Poplar, Montana. Our audit concentrated
on leasing activities that occurred during calendar years
1993 through 1997; however, we expanded the scope in the
area of our review of revenues in special deposit (suspense)
accounts to determine whether lease rents and grazing fees
were distributed to landowners regardless of when deposits
were made. Because the grazing function was only recently
assumed by the Fort Peck Tribes and a complete operating
cycle had not occurred at the time of our review, we
eliminated grazing from our audit scope. However, we did
analyze the reasonableness of the Area Director's minimum
grazing rates for allotted lands included in the range
units.
Our audit was conducted in accordance with the "Government
Auditing Standards," issued by the Comptroller General of
the United States. Accordingly, we included such tests of
records and other auditing procedures that were considered
necessary under the circumstances. As part of our review,
we assessed the Bureau's system of internal controls and
found weaknesses related to reissuing expired leases and
clearing special deposit accounts. These weaknesses are
addressed in the Results of Audit section of this report.
Our recommendations, if implemented, should improve the
internal controls in these areas.
We also reviewed the Department's Accountability Report for
fiscal year 1996 to determine whether any of the reported
weaknesses were directly related to the objective and scope
of our audit. The Report cited long-standing material
weaknesses in the Bureau's (1) management of trust funds,
the responsibility for which has been transferred to the
Office of the Special Trustee for American Indians; (2) debt
collection practices; and (3) land records management.
These weaknesses were considered in planning and conducting
our review.
PRIOR AUDIT COVERAGE
Neither the Office of Inspector General nor the General
Accounting Office has issued an audit report during the past
5 years on agricultural leases and grazing permits
administered by the Fort Peck Agency. However, in January
1998, the Office of Inspector General issued the audit
report "Financial Statements for Fiscal Year 1996 for the
Office of the Special Trustee for American Indians Tribal,
Individual Indian Monies, and Other Special Trust Funds
Managed by the Office of Trust Funds Management" (No. 98-I-
206). The report presented the results of the audit of the
statement of assets and trust fund balances and the
statement of changes in trust fund balances for tribal,
individual Indian monies, and other special trust funds as
of and for the year ended September 30, 1996, performed by
an independent certified public accounting firm. The report
on internal controls stated that "the OTFM [Office of Trust
Funds Management] and the Bureau continue to be hampered by
a lack of adequate information systems to support various
trust-related activities, including land inventory systems,
lease management systems, ownership systems, accounts
receivable and an adequate trust accounting system for IIM
[Individual Indian Money]." The report identified three
reportable conditions that impacted the scope of our audit:
(1) suspense accounts were not analyzed; (2) policies and
procedures regarding special deposit accounts were lacking
and practices regarding these accounts were inconsistent;
and (3) the system of policies and procedures for
determining interest earnings for Individual Indian Monies
accounts was inadequate, which adversely impacted the
complete and timely distribution of funds to account
holders. These identified conditions and the resultant
recommendations were considered in the preparation of our
current report.
RESULTS OF AUDIT
We found that the Fort Peck Agency generally managed
agricultural and pasture leases on the Fort Peck Indian
Reservation in accordance with applicable regulatory, lease,
and permit requirements. Specifically, the Agency (1)
identified lands that were suitable for leasing;
(2) advertised, using sealed bidding procedures, those lands
that were available for lease; (3) ensured that fair annual
rents were realized based on competitive bids and
negotiations; (4) made timely distributions of rents
collected to Indian landowners; (5) assessed interest when
rents were paid late; and (6) enforced bonding requirements
stipulated in the leases. However, we also found that new
leases were not usually approved or granted by their
effective date and that some lease rents and grazing fees
which were deposited into special deposit accounts in the
1970s and 1980s had not been distributed to landowners.
Approved Leases
The Fort Peck Agency did not always approve new leases in a
timely manner. The lease documents specify that annual
rents are due in advance of the lease year and rents are
delinquent if not paid within 30 days of the due date. The
advertisement for the leases that expired on December 31,
1996, specified that at least 25 percent of the first year's
rent was due at the time that the lease bid was submitted
and that the remaining portion of the rent was due at the
time the lease was executed and approved. We reviewed the
Agency's lease logbook to determine the timeliness of
approving new leases and found that 115 (31 percent) of the
371 farm and pasture leases which expired on December 31,
1996, were approved timely. Of the remaining 256 leases,
224 leases were approved and granted up to 195 days after
the leases' effective dates, and 32 leases had not been
granted at the time of our audit site visit in June 1997, or
almost 6 months past the due date. Because Agency realty
personnel stated that approving the larger dollar leases was
their priority in awarding leases, we reviewed all 50 leases
that had annual rents of $3,000 or more (based on the
Agency's universe of leases rents, we classified leases
with annual rents in excess of $3,000 as large dollar
leases) which expired on December 31, 1996. We found that
only half of these leases were approved and granted by the
December 31 expiration date or within 30 days of the
expiration date and that half of the leases, which had total
annual rents of about $125,000, were approved and granted
from 34 to 161 days after the leases expired. Because the
leases were not approved and granted in a timely manner, the
landowners did not receive their rents timely.
According to Agency realty personnel, the Agency did not
have sufficient realty staff to simultaneously approve and
grant leases by January 1, 1997, and to collect and
distribute lease rents on continuing leases. Agency realty
personnel further stated that their work load priority was
to distribute rents which had been collected for continuing
leases before they processed new leases.
Special Deposit Accounts
While the Agency effectively distributed current lease rents
and grazing fees deposited into special deposit accounts, it
did not analyze older special deposit accounts to ensure
that the account balances were correct and that funds in
these accounts were properly distributed.[4] The Code of
Federal Regulations (25 CFR 114) specifies that special
deposit accounts are to be used for the temporary deposit of
funds which cannot be credited to specific accounts or
readily distributed. However, we identified revenues of
about $164,100 that had accumulated in 56 special deposit
accounts since the 1970s and 1980s.
Our analysis of the 56 special deposit accounts disclosed
that the accounts were established in the 1960s and 1970s
and have had continuing balances since the 1970s. These
accounts have been inactive (including the posting of any
interest income earned) since 1988. However, the crediting
of interest income to the accounts would significantly
increase the $164,100 balance. Personnel in the Billings
Area and Fort Peck Agency Offices stated that the special
deposit account balances for some of these 56 accounts were
in error because entries for a distribution of funds by the
Area Office during the mid-1980s were not posted to the
affected special deposit accounts. However, neither the
Area Office nor the Agency Office provided documentation to
support this position. We believe that the Agency, in
coordination with the Office of the Special Trustee for
American Indians, should analyze these accounts to ensure
that Indian landowners receive all funds which they are due.
Recommendations
We recommend that the Assistant Secretary for Indian Affairs
ensure that the Fort Peck Agency:
1. Initiates the lease renewal process in sufficient
time to complete the approval process before the effective
date of agricultural and pasture leases.
We recommend that the Assistant Secretary for Indian Affairs
and the Special Trustee for American Indians ensure that the
Fort Peck Agency:
2. Researches the 56 special deposit accounts which
have old balances and updates the accounts for distributions
that were made previously but not recorded. For amounts
that have not been distributed, the owners should be
identified, the interest should be computed and posted, and
the funds should be distributed.
We recommend that the Special Trustee for American Indians:
3. Establish and implement procedures to periodically
analyze and distribute, in a timely manner, funds that are
in special deposit accounts.
Bureau of Indian Affairs Response and Office of Inspector
General Reply
In the February 20, 1998, response (Appendix 1) to the draft
report from the Assistant Secretary for Indian Affairs, the
Bureau nonconcurred with Recommendation 1 and did not
address Recommendations 2 and 3, stating that "authority in
this area [special deposit accounts] is delegated to the
Special Trustee [for American Indians]." Based on the
Bureau's response, we have revised Recommendation 1 and
request that the Bureau respond to the revised
recommendation, which is unresolved (see Appendix 3). The
Office of the Special Trustee for American Indians provided
a response (Appendix 2) to Recommendations 2 and 3 (see
section "Office of the Special Trustee for American Indians
Response and Office of Inspector General Reply"). Based on
the two responses, we have directed Recommendation 2 to the
Assistant Secretary for Indian Affairs and the Special
Trustee for American Indians and Recommendation 3 to the
Special Trustee for American Indians.
Recommendation 1. Nonconcurrence stated.
Bureau of Indian Affairs Response. The Bureau
nonconcurred with the recommendation to approve agricultural
and pasture leases in a timely manner, stating that "there
is no prescribed time frame or legal deadline by which a
lease agreement must be approved." Additionally, the Bureau
stated that "there is no basis in statute or regulation for
establishing `timeliness.'" According to the Bureau, "There
are various reasons why a new lease may not be in place upon
the expiration [December 31] of a current lease and a number
of these reasons are beyond the Bureau's control." Further,
the Bureau stated that "the Agency's goal is to ensure that
agricultural leases are processed by April so that
. . . pasture leases are approved prior to the May 1 turn
out date."
Office of Inspector General Reply. Although Bureau
regulations do not prescribe a specific time frame for
approving agricultural leases, the Government Performance
Results Act requires that agencies conduct processes in a
businesslike manner. Regarding the "various reasons" as to
why a new lease may not be in place when a current lease
expires and the reasons that are "beyond the Bureau's
control," we believe that some matters may be beyond the
Bureau's control but that some may just take longer to
complete than the Fort Peck Agency has allowed for in its
leasing process. In this regard, the Bureau and the Agency
should determine the amount of time necessary to complete
the leasing process, establish an effective date for leases
based on Agency-related conditions for beginning farming
operations, and initiate the renewal process allowing
sufficient time to complete actions by the effective date.
Our report (No. 97-I-1100) on the Colorado River Indian
Tribes' management of agricultural leasing showed that the
Tribes "initiated actions in a timely manner to ensure that
expiring leases were reissued [approved] without a loss of
revenue to the landowners." Similarly, we believe that the
suggested actions will provide the Bureau with the basis for
measuring the Agency's performance for accomplishing its
goal "that agricultural leases are processed by April" and
also provide the individual landowners with a date when they
can reasonably expect lease payments to begin. We have
revised the recommendation to focus on the timing of
initiating the lease renewal process and the establishment
of a lease effective date.
Recommendations 2 and 3. Concurrence/nonconcurrence not
stated.
Bureau of Indian Affairs Response. The Bureau noted
that while the report acknowledged the Special Trustee's
responsibility, "the recommendations were directed to" the
Assistant Secretary for Indian Affairs rather than the
Special Trustee for American Indians. The Bureau stated
that while it has "every intention of working closely and
cooperatively with the Special Trustee," it has not
"address[ed] these two recommendations as authority in this
area [special deposit accounts] is delegated to the Special
Trustee." The Bureau requested that "the section on Special
Deposit Accounts be eliminated from the report or included
under Other Matters with appropriate reference to the
financial statement audit report."
Office of Inspector General Reply. As a result of the
Bureau's response, we requested written comments to
Recommendations 2 and 3 from the Office of the Special
Trustee for American Indians, and we received a response on
June 12, 1998. Based on the responses, we have addressed
Recommendation 2 to both the Special Trustee and the
Assistant Secretary because the Special Trustee is
responsible for management of Indian trust assets, including
special deposit accounts, and the Assistant Secretary,
through the Bureau, controls many land and related records
needed to research and update the special deposit accounts.
Further, both organizations have expressed the willingness
to work cooperatively to resolve the matter. We have
addressed Recommendation 3 to the Special Trustee because
the Special Trustee is responsible for establishing
consistent written policies and procedures for trust fund
management and accounting. We also added, to the Prior
Audit Coverage section, reference to the January 1998 Office
of Inspector General audit report "Financial Statements for
Fiscal Year 1996 for the Office of the Special Trustee for
American Indians Tribal, Individual Indian Monies, and Other
Special Trust Funds Managed by the Office of Trust Funds
Management" (No. 98-I-206) because the report discusses the
overall weakness in accounting for individual Indian money
accounts, including special deposit accounts. However, we
did not, based on the financial statement audit of the trust
funds, eliminate or move to an Other Matters section of the
report our finding on special deposit accounts because our
finding accurately describes a condition we identified at
the Fort Peck Agency and because the High Level
Implementation Plan of the Trust Management Improvement
Project, which details Departmental actions to improve trust
fund accounting, had not been issued or referred to the
Assistant Secretary for Policy, Management and Budget for
tracking of implementation. This occurred because the
Implementation Plan was not issued until July 1998, or 6
months after the report was issued.
In its response, the Bureau provided additional comments on
the report as follows:
- Results of Audit. The Bureau disagreed with the our
use of the words "issuing" and "reissuing" leases rather
than "granting" or "approval" of leases, which it said were
the terms used in the statutes and regulations. We have
revised the report as appropriate to correct the
terminology.
- Other Matters. The Bureau disagreed with the
inclusion of the Other Matters section in our report
concerning the establishment of the Area Director's
reservation minimum acceptable grazing rate for all
individually owned lands. The Bureau stated that "the
minimum rate has to be established prior to the bidding" on
the advertised range units. Therefore, according to the
Bureau, it would not be possible to determine whether the
minimum rate compares favorably to the bid rates until after
the "bids are received." In addition, the Bureau stated:
There is a difference between a minimum acceptable
bid for any range unit on the reservation and the
highest bid that the best range unit may command.
That distinction is not made in the report.
Unallocated range units advertised for grazing
permits represent a diminishing resource for non-
tribal ranchers, and as such, command higher
competitive prices which are not necessarily
indicative or representative of fair market values
for the vast majority of the reservation lands.
We provided this information as other matters to inform
management about a situation that we believe should be
considered when determining fair annual return to allottees
whose lands are included in allocated range units. However,
since completion of our fieldwork, the General Accounting
Office has initiated a review of the Bureau's appraisal
process. In addition, the Trust Management Improvement
Project includes a subproject to review the Bureau's
appraisal program. Therefore, based on the Bureau's
comments and the other comprehensive reviews, we have
deleted the Other Matters section from the final report.
Office of the Special Trustee for American Indians Response
and Office of Inspector General Reply
In the June 12, 1998, response (Appendix 2) to the draft
report from the Deputy Special Trustee for Operations,
Office of the Special Trustee for American Indians, the
Office concurred with Recommendations 2 and 3. Based on the
response, we consider Recommendations 2 and 3 resolved but
not implemented. Accordingly, the unimplemented
recommendations will be referred to the Assistant Secretary
for Policy, Management and Budget for tracking of
implementation (see Appendix 3).
Recommendation 2. Concurrence stated.
Office of the Special Trustee for American Indians
Response. The Office stated that the "56 special deposit
accounts have to be updated and distributed and [the Office]
agrees to work in coordination with the Assistant Secretary
- Indian Affairs, and the Bureau of Indian Affairs (BIA)
field staff." According to the Office, Bureau of Indian
Affairs realty field staff needs to research the 56 special
deposit accounts as to ownership and distribution, and the
Office of Trust Funds Management can then post the
distribution and "perform the necessary interest
calculations." The Office stated that, "[t]he research and
clearing of Special Deposit accounts has surfaced" as an
issue in the Trust Management Improvement Project. The
Office further stated, "A separate, joint OST/BIA [Office of
the Special Trustee for American Indians and Bureau of
Indian Affairs] effort, most likely on an Area by Area
basis, is the likely approach."
Office of Inspector General Reply. We noted that the
High Level Implementation Plan for the Trust Management
Improvement Project includes four subprojects which will
address the deficiencies with special deposit accounts:
Office of the Special Trustee financial data cleanup, Bureau
of Indian Affairs resource data cleanup, Bureau probate
backlog, and Office of Hearings and Appeals probate backlog.
Based on the subprojects included in the Implementation
Plan, we consider the recommendation resolved.
We recognize that other audit reports, such as the audit of
the Office of the Special Trustee's financial statements for
trust funds for fiscal year 1996 (Report No. 98-I-206),
contain recommendations that address special deposit
account balances, and we will coordinate with the Assistant
Secretary for Policy, Management and Budget to ensure a
single tracking of implementation efforts on the basis of
the Implementation Plan dated July 1998.
Recommendation 3. Concurrence stated.
Office of the Special Trustee for American Indians
Response. The Office agreed to "work in coordination" with
the Assistant Secretary for Indian Affairs and the Bureau on
this recommendation, stating that it is taking "a national
approach to this issue, rather than focusing on any single
agency" and that it will "develop standardized policy and
procedures for special deposit accounts."
Office of Inspector General Reply. Based on the
response, we consider the recommendation resolved but not
implemented.
In accordance with the Departmental Manual (360 DM 5.3), we
are requesting written responses to this report by November
9, 1998. The responses should provide the information
requested in Appendix 3.
The legislation, as amended, creating the Office of
Inspector General requires semiannual reporting to the
Congress on all audit reports issued, actions taken to
implement audit recommendations, and identification of each
significant recommendation on which corrective action has
not been taken.
We appreciate the assistance of Bureau and Office personnel
in the conduct of our audit.
**FOOTNOTES**
[1]:"Individually owned land" as used in the Code of Federal
Regulations (25 CFR 162 for leasing and 25 CFR 166 for grazing) is defined
as "land or any interest therein held in trust by the United States
for the benefit of individual Indians and land or any interest therein
held by individual Indians subject to Federal restrictions against
alienation or encumbrance."
[2]:Fractionated ownership has resulted because many
Indians died without wills. As a result, over a period of
generations, many allotments became jointly owned by hundreds of heirs.
[3]:A range unit is a tract of land designated as a management
unit for administering grazing and may include tribal, allotted, fee,
and/or Government lands that have been consolidated for grazing
administration.
[4]:The Bureau is responsible for administering leases on
tribal and individually owned lands. However, the Department's Office
of the Special Trustee for American Indians is responsible for
establishing proper controls and accountability for managing trust funds,
including trust funds deposited in the Individual Indian Money accounts
system, which includes special deposit accounts.
APPENDIX 1
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APPENDIX 1
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APPENDIX 1
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APPENDIX 1
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APPENDIX 1
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APPENDIX 2
APPENDIX 1
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APPENDIX 3
STATUS OF AUDIT REPORT RECOMMENDATIONS
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Finding/
Recommendation
Reference Status Action Required
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1 Unresolved. Provide a response to the revised
recommendation. If
concurrence is indicated, provide a
plan identifying actions
to be taken, including the target date
and the title of the
official responsible for
implementation. If nonconcurrence
is indicated, provide specific reasons
for the
nonconcurrence.
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2 and 3 Resolved; No further response to the Office of
Inspector General is
not required. The recommendations will be
referred to the
implemented. Assistant Secretary for Policy,
Management and Budget for
tracking of implementation.
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